Joint feedback by energy intensive industries to the Expert Group on Climate Change Policy

Apr 18, 2023

List of topics

  1. Climate neutrality plans: application at sub-installation instead of installation level
    a. The precedent of the activity level changes applied at sub-installation level
    b. The reference to “product benchmarks” in article 10a paragraph 1
    c. Only article 10b(4) “shall be read as to referring to installation level”
    d. Inconsistency with the legal wording of the Directive (penalty also to fall back benchmarks
    e. Distortion of competition among installations
  2. Climate neutrality plans: targets and milestones based on measures and investments instead of
    emissions reduction
  3. Energy efficiency conditionality: sufficient time for implementing audits’ recommendations
  4. Historical activity level

The whole document can be downloaded here.